MiCA 2.0: EU Eyes Rules for Non-EU Stablecoin Issuers
EU officials are reportedly preparing to revisit the Markets in Crypto-Assets regulation with a specific focus on stablecoins issued by non-EU entities. Triggered in part by the passage of US stablecoin legislation, the proposed revision would extend MiCA's reach to cover companies like US-domiciled stablecoin issuers operating in EU member states. For accounting firms, auditors, and CFOs carrying crypto on their books, this is not a distant policy question. It reframes the compliance perimeter for stablecoin accounting and the client advisory work that surrounds it.
What the Reports Say About MiCA 2.0
According to a report by Euronews published on 8 July 2026, EU officials are planning to consider revisions to MiCA in 2027. The driver is straightforward: the US Guiding and Establishing National Innovation for US Stablecoins Act, commonly known as the GENIUS Act, has created a domestic legal framework for dollar-backed stablecoins in the United States. That development has, according to the report, put pressure on EU policymakers to clarify how US-domiciled stablecoin issuers can be regulated when they serve customers across the EU's 27 member states.
The proposed revisions would also potentially extend MiCA to cover tokenized payments and deposits, an area the current regulation does not comprehensively address. A public consultation on the broader MiCA 2.0 framework was reportedly open for comment until 31 August, suggesting the formal legislative process is still in early stages.
The 2028 Timeline Reality
Senior legal practitioners are tempering expectations. Taylor Wessing senior associate Miroslav Durić told Cointelegraph in June that concrete legislative proposals are unlikely before 2028. That matters operationally: firms that treat this as an imminent change will over-invest in compliance infrastructure too early, while firms that dismiss it entirely will be caught flat-footed when the consultation closes and the European Commission begins drafting. The practical window for preparation is now, not when the legislative text arrives.
Why the GENIUS Act Changed the Calculus for EU Regulators
MiCA, as enacted, requires any crypto-asset service provider offering services to EU-based users to hold a CASP licence from a regulator in at least one member state. That licensing obligation came into full effect on 1 July 2025. However, the regulation was not designed with a robust extraterritorial stablecoin issuer framework in mind. A US entity issuing a dollar-denominated stablecoin under the GENIUS Act and distributing it to EU retail or institutional users sits in an ambiguous regulatory position today.
The GENIUS Act creates a federal licensing pathway for US stablecoin issuers and imposes reserve and disclosure requirements under US jurisdiction. From a Brussels perspective, this is a foreign regulatory approval that does not automatically satisfy MiCA's requirements, particularly around reserve asset composition, redemption rights, and ongoing supervisory access. The potential for regulatory arbitrage, where a US-licensed issuer serves EU customers without equivalent EU oversight, appears to be what is prompting the revision discussion.
Tokenized Deposits: The Quiet Addition
The reported expansion into tokenized payments and deposits deserves separate attention. Tokenized deposits sit at the intersection of banking regulation and crypto-asset regulation, and their treatment under current MiCA text is contested. If the revision brings them within scope, banks and e-money institutions that are experimenting with tokenized deposit products will need to assess whether they require a CASP licence in addition to their existing banking authorisation. That is a non-trivial compliance question with direct implications for legal entity structuring and balance sheet classification.
ESMA's Concurrent Supervisory Focus
The timing of this policy discussion overlaps with active supervisory work. The European Securities and Markets Authority has indicated it plans to review the operational resilience of CASPs licensed under MiCA, with a focus on custody-related operational risks. This review is scheduled to run from July through the first half of 2027, the same window in which EU officials are reportedly deliberating on the MiCA 2.0 revisions.
What ESMA's Custody Review Means Alongside the Revision
For accounting firms with CASP clients, the simultaneous operational resilience review and the legislative revision process create a dual advisory mandate. Clients need to satisfy ESMA's current supervisory expectations on custody, while also monitoring the direction of the legislative changes that could alter the competitive landscape if non-EU issuers are brought within scope. Managing both tracks in parallel is the near-term challenge.
Accounting Implications: IFRS and US GAAP
The proposed MiCA revision has layered accounting consequences, particularly for entities holding or distributing stablecoins issued by non-EU issuers.
IFRS Treatment of Non-EU Stablecoins
Under IFRS, the classification of a stablecoin on an entity's balance sheet depends on its contractual characteristics and the business model under which it is held. A stablecoin that confers a right to redeem for a fixed monetary amount from the issuer is typically assessed under IFRS 9 as a financial asset, potentially as a financial liability of the issuer. If the MiCA revision imposes new reserve and redemption requirements on non-EU issuers serving EU clients, the contractual terms of some stablecoins may change. That could trigger a reclassification assessment under IFRS 9, or at minimum require updated disclosure under IFRS 7 to reflect the revised regulatory environment governing the asset.
Entities applying IAS 1 will need to consider whether the regulatory uncertainty itself requires disclosure. A stablecoin issuer that is not yet licensed under the revised MiCA but whose product is widely held by EU counterparties represents a concentration risk that may need to be articulated in notes to the financial statements.
For broader context on how IFRS interacts with EU financial regulation, the EBA 2027 stress test framework and its IFRS 9 implications illustrates how supervisory requirements can reshape accounting judgements.
US GAAP Considerations Under ASC 350-60
For US-domiciled entities or those reporting under US GAAP, the Financial Accounting Standards Board's ASC 350-60, which introduced fair value measurement for certain crypto assets, is the relevant framework. Stablecoins are generally excluded from ASC 350-60's scope because they do not meet the definition of an intangible asset in the same way as volatile crypto assets. They are typically held as cash equivalents or financial instruments depending on their liquidity and redemption characteristics.
However, a MiCA revision that introduces new regulatory conditions on non-EU issuers operating in the EU could affect the liquidity and convertibility profile of specific stablecoins for EU-based holders. If a particular stablecoin becomes restricted or subject to operational hold conditions pending issuer licensing, the cash-equivalent classification under ASC 230 may no longer hold. Treasury and accounting teams at US multinationals with European operations need to monitor this proactively.
Practical Steps for Accounting Firms and CFOs
The legislative timeline extends to 2027 for consideration and potentially 2028 for concrete proposals, but waiting is not a viable advisory posture. The following steps are relevant now.
Audit and Update Stablecoin Inventory
Accounting firms should work with clients to identify every stablecoin held on the balance sheet, including those held indirectly through fund structures or treasury management accounts. For each, identify the issuer's domicile and current regulatory status under MiCA. Non-EU issuers with significant EU exposure are the highest-priority items in this review. This inventory feeds directly into both the IFRS 7 disclosure assessment and the ASC 230 classification review.
Assess CASP Counterparty Risk
If clients are using CASPs to hold or trade stablecoins issued by non-EU entities, those CASPs need to be reviewed for their own compliance posture. Belgium's FSMA has already flagged unauthorised CASPs following the MiCA deadline, as covered in detail in the Belgium FSMA enforcement action analysis. A CASP that is not properly licensed and is handling non-EU stablecoins carries compounded counterparty risk that auditors need to surface.
Monitor the Consultation Window
The MiCA 2.0 consultation reportedly closes on 31 August. Firms that have material stablecoin exposure, either their own or through clients, should consider submitting or reviewing consultation responses. Regulatory consultations are a direct channel for practitioner input, and the outcomes influence the final legislative text. An FCCA-qualified practitioner advising on stablecoin accounting is precisely the type of respondent the European Commission needs to hear from.
Prepare for Tokenized Deposit Classification Questions
If the revision brings tokenized deposits into MiCA's scope, the accounting treatment question becomes urgent. Are tokenized deposits financial instruments under IFRS 9? Are they deposits under the EU's Deposit Guarantee Scheme Directive? The intersection of banking law, e-money regulation, and crypto-asset regulation here is genuinely complex. Firms should begin building their technical positions now rather than waiting for the legislative text, as clients will ask the moment headlines break on the final rules. The UK stablecoin regulatory framework and its IFRS implications provides a useful comparative reference for how a major jurisdiction has approached this classification challenge.
The US-EU Regulatory Interaction
One aspect of this development that is easy to understate is that it represents the first time a major piece of US crypto legislation has directly influenced EU regulatory revision. The GENIUS Act passing through the US legislative process and prompting a European regulatory response signals a degree of regulatory interdependence that will only increase as stablecoin volumes grow. For multinational clients, this means that stablecoin compliance is no longer a single-jurisdiction exercise. A client holding USDC in a European treasury must now monitor both the US regulatory environment governing the issuer and the EU regulatory environment governing its own use of that asset.
The parallel US legislative activity around the Digital Asset Market Clarity Act, which was reportedly advancing through the Senate in July, adds another layer. If the CLARITY Act progresses, it will further define how digital assets are classified under US law, which in turn affects how EU regulators calibrate the equivalence or mutual recognition provisions of any revised MiCA text.
Frequently Asked Questions
What is MiCA 2.0 and when will it take effect?
MiCA 2.0 is the informal label for a proposed revision to the EU's Markets in Crypto-Assets regulation. EU officials are reportedly set to consider the changes in 2027. Based on public commentary from legal practitioners, concrete legislative proposals are unlikely before 2028, with an implementation period after that.
How would MiCA's proposed revision affect US stablecoin issuers serving EU clients?
The reported aim is to bring non-EU stablecoin issuers within MiCA's regulatory perimeter when they serve EU-based users. This would likely require them to comply with MiCA's reserve, redemption, and disclosure requirements, or to operate through an EU-licensed entity. The specifics depend on the final legislative text, which has not yet been drafted.
Does holding USDC or another US-issued stablecoin on an EU balance sheet create a compliance problem today?
Under current MiCA text, the immediate compliance obligation falls on the CASP distributing or holding the stablecoin in the EU, not necessarily the end holder. However, the proposed revision could change that. Holders should review their IFRS 7 disclosures and ensure they understand the regulatory status of the issuer under both US and EU frameworks. If the issuer is not licensed under MiCA as an e-money token issuer or asset-referenced token issuer, that is a risk factor worth documenting.
What is ESMA reviewing under its operational resilience programme, and does it affect my firm now?
ESMA's review focuses on custody-related operational risks at MiCA-licensed CASPs. It runs from July 2026 through the first half of 2027. If your firm uses or audits a MiCA-licensed CASP that holds stablecoins on behalf of clients, you should confirm that the CASP has adequate operational resilience documentation in place, including business continuity, key management, and segregation of client assets. ESMA's findings from this review may also inform the MiCA 2.0 revision drafting.
Should accounting firms respond to the MiCA 2.0 consultation before 31 August?
Yes, if you have material stablecoin or digital asset exposure in your client base. Public consultations directly shape the legislative text that follows. Practitioners with technical accounting expertise in stablecoin classification under IFRS or US GAAP are well-placed to provide input that may not otherwise reach policymakers. At minimum, review the consultation document to understand the direction of travel before it closes.
Source: Cointelegraph